Subject of Dispute: Recognition as Unlawful and Cancellation of a Tax Notification-Decision Regarding Violation of Registration Deadlines for Adjustment Calculations to Tax Invoices in the Unified Tax Invoice Register.
Main Court Arguments:
The Supreme Court formulated a fundamentally new legal position that the registration period for an Adjustment Calculation (AC) should be calculated from the day of the actual receipt of the document by the buyer, rather than from the day of its preparation by the supplier. The court emphasized that the buyer cannot be held responsible for delays that occur before the document is received, since the AC is initiated and formed exclusively by the supplier.
Court Decision: To cancel the decisions of previous instances and refer the case for a new review to fully investigate all provided evidence regarding the date of receipt of adjustment calculations.